land off front street at slip end, luton

KINGSTON UPON THAMES • CAMBRIDGE www.allenpyke.co.uk Landscape • Urban • Environmental

GREEN BELT REVIEW

Land off Front Street at Slip End, Luton

Prepared on behalf of:

Legal and General

Ref: 2728-RE-02-P4

Date: August 2017

Allen Pyke Associates

Land at Slip End, Luton: Green Belt Review APAL Ref: 2728-RE-02-P4

EXECUTIVE SUMMARY

Introduction

The joint Legal & General and Luton Hoo Estate landholding at Slip End is located in the Central Bedfordshire Council’s administrative area and lies within designated Green Belt. The local authority have identified the need to use Green Belt land for development, particularly in the southern parts of the district where major pressure for future residential growth is greatest around the large towns of Luton, Dunstable and Houghton Regis.

Slip End has a population of under 2,000 but is classified as a large village in the Central Bedfordshire Local Plan. The settlement is located beside Junction 10 of the M1 motorway, which separates it from the south-western edge of Luton. The L&G land is located between the eastern settlement boundary of Slip End and the M1 junction, where it shares a common boundary with the entire eastern perimeter of the site.

Landscape Context and Attributes

The rural landscape around Slip End consists of a series of dispersed small villages and hamlets set within a mosaic of fields with large areas of woodland, hedgerow-lined field and road boundaries that create an enclosed or semi-enclosed countryside. The countryside around the MI junction consists of the undulating chalk landscape of the Chilterns with its wide flat ridges on the dip slopes and steep sided valleys.

Slip End is positioned on an elevated dip slope that gradually falls southwards and eastwards across the L&G land to the motorway. The adjacent part of the Luton settlement boundary is occupied by an extensive sports and recreational area that straddles a ridge at Stockwood Park on the opposite side of the M1 to the L&G land.

L&G Land

The L&G site covers approximately 20 hectares with a proposed net developable area of 12 hectares, which consists of the main single, elongated and irregularly shaped field currently under arable agricultural production and an area of allotments. The balance of the land is to be used to create extensive boundary landscape buffers incorporating the substantial existing boundary tree belts and hedgerows, the primary area being along the motorway boundary.

The developable area within the landholding is surrounded by tall vegetation creating an enclosed site with little visual intervisibility with the adjacent countryside and a limited zone of visual influence around the site boundary and Slip End.

Development Proposals

The scheme proposals would create a high quality residential development of predominantly 2 storey dwellings that would be set within a robust green framework. Housing styles, the scale of development and selection of materials would be sympathetic to the location.

The remaining 8 hectares would include a landscape buffer and amenity spaces of up to 100 metres in width along the motorway boundary. The proposed development would be set around a new village green and will provide a focal point for Slip End. The scheme layout would incorporate and reinforce the existing tree belt and provide informal incidental recreational areas and equipped children’s play space. The existing public footpath and bridleway crossing the landholding would also be retained in attractive green corridors to encourage their use. The existing allotments would be relocated within the new development.



The landscape strategy for the site would create an attractive new living environment for residents with the boundary buffers establishing a well-defined, enduring and appropriate new settlement edge to Slip End along the motorway boundary.

Green Belt Appraisal

In July 2017 Central Bedfordshire and Luton Borough Council jointly published an updated Green Belt Study as part of the evidence base for their emerging Local Plans. The document post-dates the ‘Turner’ judicial review in 2016 but follows the traditional ‘volumetric’ approach to the assessment of the purposes of the Green Belt. The document omits the ‘visual dimension’ the Turner ruling suggests is implicit in the interpretation of the National Planning Policy Framework guidance on Green Belt assessments.

The 2017 Study followed a two-stage process identifying larger parcels of Green Belt land, which were tested against the purposes of the Green Belt as defined in the NPPF. A more detailed second stage reviewed of land that contributed ‘weakly’ or ‘relatively weakly’ against the purposes of the Green Belt and were, therefore, considered of lower risk of harm for release from the designation.

The L&G land was carried forward into the second stage assessment as part of ‘Area SE1a’ that wrapped around the southern part of the Slip End settlement boundary. The Study considered the area to be borderline in terms of its contribution to the purposes of the Green Belt. However, the higher ranking ‘moderate’ contribution to preventing encroachment of the countryside meant in volumetric terms the parcel was not recommended for release.

Having completed the study, Central Bedfordshire had to accept that the exercise identified the release of less than 1% of the Green Belt, which was insufficient for their development requirements and, in addition, not all of this weakly performing land was suitable for development. The Study concluded that it will be necessary to release better performing areas of Green Belt land in order to realise the strategy set out in the Local Plan, although no indication was given of a new selection threshold being set.

Conclusions of this Green Belt Review

The landscape and visual appraisal prepared on behalf of Legal & General established that their landholding and allotment area was not subject to any landscape or environmental designations, it was not an area of heritage significance to the village, and the landscape and physical attributes were not sufficient to warrant the landholding being recognised as a locally valued landscape.

The Review took into consideration the visual openness aspects of the Green Belt, in accordance with the Turner ruling, and found the L&G landholding to perform more weakly in terms of its contribution to the purposes of the Green Belt than the local authority’s 2017 Study findings. The conclusion being that the landholding should qualify in its own right for consideration as a weaker category site of low risk of harm for release from the Green Belt.

The character and visual characteristics of the L&G landholding were not considered by the Review to be typical of the area around Slip End. The greater sense of landscape and visual enclosure, and limited intervisibility make the L&G site capable of accommodating residential development without detriment to the character and integrity of the surrounding areas of Green Belt countryside.

The L&G land at Slip End is, therefore, suitable for consideration for release from the Green Belt as a residential allocation in the emerging Central Bedfordshire Local Plan.



LAND OFF FRONT STREET AT SLIP END, LUTON GREEN BELT REVIEW CONTENTS:

Page:

1. Introduction 1 2. Scope of Review 2 3. Appraisal of Landscape and Visual Attributes 7 4. Development Proposals 14 5. Green Belt Appraisal 16 6. Summary and Conclusions 27


Land at Slip End, Luton: Green Belt Review APAL Ref: 2728-RE-02-P4 1

1. INTRODUCTION

1.1. This report has been prepared by Allen Pyke Associates Ltd (APAL), a landscape design consultancy

specialising in landscape character and visual assessments across a variety of scales and types of

development. The practice has over twenty years’ experience of preparing landscape studies in

support of planning applications for major developments on Green Belt land and other designated

or sensitive valued landscapes.

1.2. The practice has been commissioned by Legal and General (L&G) to provide landscape advice in

association with Savills planning consultancy for a residential development on their landholding

off Front Street in the village of Slip End, which is located to the south-west of Luton in

Bedfordshire beside Junction 10 of the M1 motorway.

1.3. Allen Pyke Associates are familiar with the site having worked with Savills on behalf of L&G on the

initial feasibility studies and LVIA assessment work for the landholding since 2003. The site was re-

visited in 2010 after completion of improvements to Junction 10 and further visits were made in

May 2016 and March 2017 to confirm existing conditions and update photographs taken from key

visual receptors around the site.

1.4. This document will review the landscape and visual aspects of the purposes and openness of the

Green Belt designation and their significance in relation to the L&G landholding and the Luton Hoo

Estates allotment area off Front Street that jointly form the proposed residential development

area.

1.5. The report should be read in conjunction with a companion ‘Landscape Appraisal’ for the site (ref:

2728-RE-01-P4), which has also been produced by APAL.



2. SCOPE OF REVIEW

Background

2.1. The role of the London Metropolitan Green Belt, which washes over the southern part of the

Central Bedfordshire administrative area, is to prevent urban sprawl and the merging of larger

towns, as well as preserving the separation between these settlements and the outer built edge

of the capital. The fundamental aim of Green Belt is to keep land beyond defined urban boundaries

permanently open.

2.2. The National Planning Framework (2012) (NPPF) sets out in Section 9 national policy on protecting

Green Belt land. The chief purpose of the document is to assist the planning system in achieving

sustainable development (para. 6) and promoting sustainable patterns of development in Green

Belt (NPPF para. 84).

2.3. Green Belt is not an environmental policy designed to protect the condition of land or high quality

landscapes. The designation does include valued landscapes but they are subject to their own

protection policies at national and local levels.

2.4. Green Belt policy does not create an outright ban on development within the designation but does

prohibit inappropriate development, which is by definition harmful and should not be approved in

the absence of very special circumstances (NPPF para.87).

2.5. There is no defined method, or accepted standard test, for assessing the potential effects of

development on ‘openness’ or the purposes of the Green Belt designation. Traditionally, this has

been a planning exercise that considers development in purely ‘spatial’ or ‘volumetric’ terms,

either on ‘greenfield’ land or as a comparison of footprint, height and volume on previously

developed land.

2.6. The ‘Turner’ High Court judicial review of May 2016 (John Turner v Secretary of State for

Communities and Local Government and East Dorset Council) has confirmed that a ‘visual

dimension’ should be included in the assessment of the purposes of the Green Belt as implied by

NPPF para. 81. Therefore, this review will examine the visual relationship of the site with the

surrounding Green Belt landscape, which is described in the companion ‘Landscape Appraisal’.



2.7. This information will be used to provide a peer review of the visual contribution the site makes to

the purposes of the Green Belt (NPPF para. 80) and the significance of the effects of its use for

residential development on the integrity of the remaining adjacent designated countryside.

2.8. Central Bedfordshire Council (CBC) commissioned Land Use Consultants (LUC) to produce a

‘Central Bedfordshire and Luton Green Belt Study’ as part of the evidence base for their emerging

Local Plan. The LUC document was prepared in November 2016 but only released by CBC to the

public in July 2017 with a short explanatory preface.

2.9. The document contains a review of ‘good practice’ precedents in planning procedures and

planning guidance for the assessment methodology but makes no mention of the Turner

judgement or the adoption of a visual dimension to the assessment. Paragraph 3.12 of the study

confirms the traditional ‘spatial/volumetric’ approach to the appraisal:

“Openness in a Green Belt sense relates to the lack of built development more than visual openness,

although the two often go hand in hand. The key distinction is that where vegetation provides

visual enclosure this does not reduce Green Belt openness, even though it might in practice mean

that development would have less visual impact. Openness should be judged based on the scale

and density of existing development. The extent and form of existing development affects the

degree to which a parcel can be considered to be part of the countryside rather than an extension

of the urban/settled area, or a built-up area in its own right.”

2.10. This definition is contrary to the Turner ruling, which sees vegetation and other topographical

features as an integral part of the overall perception of Green Belt openness and the correct

interpretation of NPPF guidance. The retention of landscape features and incorporation of open

green infrastructure within a development in Green Belt has the potential to provide mitigation

that will reduce the degree of harm caused on a site as well as significantly reducing or avoiding

any impact on the integrity of the remaining wider Green Belt setting. The vegetation, landform

and resultant visual containment in and around the L&G and Luton Hoo Estate joint landholding

at Slip End are a fundamental consideration that greatly weaken any contribution the site makes

to the purposes of designation and reduce the risk of visual harm to the Green Belt.

2.11. The same authors were previously commissioned by CBC to prepare a ‘Green Belt Technical Paper’

in June 2014 as part of the authority’s ‘Development Strategy’. The purpose of the earlier

document was to set out the ‘exceptional circumstances’ by which the CBC believed it could justify



the release of Green Belt land or make changes to the boundary of the designation. These were

identified as a need for residential and employment development and to redress the significant

imbalance and deficit in the future provision of such facilities in the southern part of the district

where the population was much larger.

2.12. The 2014 study included a sequential two-stage assessment with Slip End forming part of a much

larger land parcel to the west of Luton and the M1. The conclusion reached by the study was that

development in this location “would have a significant impact upon the Green Belt and its

function”. The area was, therefore, considered to be rated ‘Red’ – the highest and most significant

contribution a land parcel could contribute to the Green Belt in the assessment’s 3-level scale.

2.13. The 2017 CBC study now also incorporates the limited areas of Green Belt land within the Luton

Borough Council settlement boundary. The study is, however, more focused on the contribution

individual land parcels make to the first four of the five purposes of the Green Belt defined in NPPF

paragraph 80. A 5-point sliding scale was used to rate the performance against each purpose, and

ranged from the highest ‘Strong Contribution’ through to lowest ‘Weak/No Contribution’ category.

2.14. The document again adopted a two-stage approach with only land parcels, or selected parts,

identified in the ‘Relatively Weak’ or ‘Weak/No Contribution’ categories in chapter 4, passing

through to the more detailed second stage. This second assessment provided a more detailed

division of each land parcel into sub-areas and explanation of the Green Belt criteria.

2.15. The land around Slip End was identified as Areas SE1 and SE2 in stage one with the L&G landholding

forming part of SE1 the south-east of the B4540 (Markyate Road/Church Road). The assessment

for both areas gave, in aggregate, an overall ‘moderate’ contribution to the purposes of Green

Belt. Although a threshold with only weaker performing land was to pass through to stage 2, both

areas were included as ‘borderline’ sites. Area SE1 was reduce in size to exclude land around

Pepperstock and was renamed Area SE1a. The L&G landholding formed a distinct part of sub-area

SE1a and was again given a ‘moderate’ aggregate rating and omitted from further consideration.

The results of the 2017 assessment are analysed fully in Section 5 of this Review document.

2.16. In assessing the Green Belt boundaries, the 2017 study also set itself the task of reviewing the

existing settlements ‘washed over’ (include within) or ‘inset’ (outside) the Green Belt in Central

Bedfordshire. Slip End is an ‘inset’ village with the settlement boundary containing all the existing

built form, with the exception of the Slip End Lower School. The recommendation in the CBC Study



is to retain the village as an ‘inset within the Green Belt’. The rationale for this conclusion is agreed

and will not be examined further.

2.17. However, following completion of their study Central Bedfordshire had to concede that having

sought to identify sufficient weakly contributing Green Belt land to meet their immediate

development requirements the main implication was:

“As less than 1% of Central Bedfordshire’s Green Belt was assessed as performing weakly, and may

not necessarily be suitable for development for a variety of reasons, it will be necessary where

exceptional circumstances apply, to release better performing areas of land in order to realise the

strategy set out within the Local Plan. This will be considered alongside other technical evidence

base studies and tested through the Examination process.”

Purpose of this Review

2.18. The Green Belt report will demonstrate that the L&G and allotments at Slip End is a ‘weaker’

performing piece of land that should be considered for release from the Green Belt for residential

purposes because there is a lower risk of harm to the designation than from the other land parcels

in the SE1a area. In making the necessary justification this document will provide::

1. A summary of the key landscape and visual characteristics of the landholding as context to the

Green Belt Review:

- Landform and topography;

- Land cover and land use;

- Built and Cultural aspects;

- Visual amenity and the intervisibility of the site and its setting; and,

- Landscape sensitivity.

2. An appraisal of the ability of the landholding to accommodate development and the landscape

mitigation measures necessary to assist the integration of any future residential proposals into the

local landscape, and reduce their potential effects on the character and visual amenity of the

immediate setting; and,

3. A strategic assessment of the contribution the landholding makes to the purposes of Green Belt

and its visual sensitivity and significance in relation to the land parcel defined in the 2017 CBC &

LBC ‘Green Belt Study’.



Methodology

2.19. The Review follows the broad best practice principles set out in the ‘Guidelines for Landscape and

Visual Impact Assessment’, Third edition, 2013 (GLVIA 3) published jointly by The Landscape

Institute and The Institute of Environmental Management and Assessment.

Assumptions

2.20. To provide a baseline for the assessment of the potential effects of residential development and

its massing, it is assumed that the built form will predominantly consist of 2-storey dwellings with

ridge heights of approximately 9 to 11 metres. This does not preclude some dwellings being of

greater height or is meant to suggest that higher buildings would be inappropriate on the site.

2.21. Layout details, house types, earthworks and associated green infrastructure would be agreed in a

full planning application and the discharge of conditions. It is assumed that any scheme proposal

would be well designed and be appropriate to the location in terms of materials, styles, landscape

treatments, scale and form.



3. APPRAISAL OF LANDSCAPE AND VISUAL ATTRIBUTES

Topography, Land Use and Setting

3.1. Slip End is a settlement with a population of approximately 1,800 that is classified in policy terms

as a ‘large village’. It lies around 2.5 km south-west of Luton town centre, and is close to the

western boundary of the M1 motorway at Junction 10 but has no direct access to the junction.

Other settlements of any appreciable size in the surrounding countryside are the villages of

Caddington, 1.2 kilometres to the north-west, and Markyate, 2.4 kilometres to the south-west.

The parish of Slip End includes the adjacent hamlets of Lower Woodside, Woodside and

Pepperstock (see Figure 1 below).

Figure 1: Aerial Photograph

3.2. The village is located on high ground within the rolling chalk landscape of the Chilterns. The area

is characterised by a series of broad ridge tops on the chalk dip slopes that are often separated by

wide, steep-sided valleys.



3.3. The L&G landholding consists of a single elongated and irregularly shaped arable field that wraps

around the eastern edge of the Slip End settlement boundary along Summer Street, The Oaks and

New Street. It also abuts the allotment area at the corner of New Street and Front Street. Beyond

the settlement boundary, the site extends along the undeveloped lengths of Church Road (B4540),

to the north, and Front Street, to the south, with the entire length of the eastern boundary being

contiguous with the M1.

The Site

3.4. The site has a gross area of 20 hectares but with a proposed net developable area of 12 hectares

because of the provision of additional substantial landscape buffers and green infrastructure to

reinforce the existing belts of vegetation along the boundary of the landholding. The highest point

is at 167m AOD along the Front Street boundary, the land then falls gently to the east and south

with some slight undulations in the field. The lowest point is at 150m AOD along the north-eastern

edge of the site, adjacent to the M1 embankment beside the Church Road bridge under the

motorway.

Land-cover and Relationship with Surrounding Countryside

3.5. Slip End and the series of dispersed small villages and hamlets that surround the settlement are

set within a mosaic of fields with large areas of woodlands, and hedgerow-lined fields and road

boundaries that run across much of the countryside to the west and south of Slip End. The

substantial framework of native vegetation contributes to the more remote rural character of this

area.

3.6. To the north of Church Road and the Markyate Road, and west of Slip End, a larger scale field

pattern becomes more evident. This landscape is partly devoid of field and road boundary

vegetation, and forms part of a wider more open section of countryside running to the west of the

M1 motorway.

3.7. Junction 10 and the motorway also mark the south-western settlement boundary to the Luton

Borough administrative area. The landscape to the east of the M1 is also dominated by Junction

10 and 10a at the head of the Luton Hoo valley. Church Road extends a short distance beyond the

motorway under-bridge to Newlands Road where the land rises to a ridge in Stockwood Park on

the edge of the Leagrave area of Luton. The park contains a number of major recreational activities

with the slopes facing Slip End and the M1 being used for a golf course (Figure 1 above).



3.8. The motorway forms a substantial physical barrier between the Luton settlement edge and Slip

End.

Built and Cultural Aspects

3.9. The entire field area within the L&G landholding and the allotments are open with no internal

blocks of vegetation, individual trees or lengths of hedgerow. The L&G land does not contain any

built form other than a local power line with a double telegraph pole carrying cables over the

north-eastern tip of the site.

3.10. All the land lies within the Green Belt designation but it is not subject to any other landscape or

environmental designations.

3.11. The Draft Caddington and Slip End Neighbourhood Plan does not identify the landholding as having

any cultural or historic associations and it is not recognised in the document as being a ‘Local Green

Space’ as defined in NPPF paragraphs 76 to 78.

3.12. The companion Landscape Appraisal demonstrates that there are no other physical attributes,

recreational, conservation, or perceptual associations to distinguish the site as being a ‘valued’

local landscape in any other regard other than its Green Belt status. The allotments are used by

the local community but will be relocated within the proposed development.

Character of the Countryside

3.13. The L&G site is lined by tall hedgerows and tree belts, which, in combination with the elevated

sections of the motorway embankments around Junction 10, create an overriding sense of

enclosure within the field area (see Figure 2: Landscape Attributes Plan, below & photographs 3.25

to 3.28 in the Landscape Appraisal).

3.14. The existing substantial tall band of trees and hedgerow vegetation along the motorway boundary

would form the base to the proposed landscape buffer and reinforced screening along the

common M1 boundary. The tall belt of mature trees running along the boundary with the rear

gardens in Summer Street, Church Road and The Oaks also provide a significant level of visual

separation between properties on these roads and the site. These properties, in combination with

the boundary trees, hide the site from the main body of the village to the west. The scale and

density of this vegetation is likely to continue providing a significance sense of screening in winter



months although the development will be more visible in the narrow visual envelop around the

site boundary.

Figure 2: Site Landscape Attributes Plan

3.15. At the southern tip of the landholding, by the motorway bridge on Front Street, is a small remnant

field that is currently visually separated from the main part of the site by the belt of tall vegetation



running along the eastern edge of the large field. It is intended that this area would also become

part of the widened landscape buffer along the M1 boundary (Figure 2 above).

3.16. Broken hedgerows line the two undeveloped sections of the road frontages on Church Road and

Front Street with mature trees allowing limiting visual permeability into the site from these local

roads. The site boundary with the allotments, located on the corner of Front Street and New Road,

is open but they are both screened from Front Street by the roadside native hedgerow.

3.17. To the immediate south of Slip End, around Pepperstock, and west of the village the ground on

the elevated, wide flat-topped ridge contains substantial areas of woodland, tree-lined lanes and

fields that enclose the village although longer views across larger open fields become more evident

to the west of the settlement. Development in Pepperstock extends along the tree-lined Half

Moon Lane but is not visible from the L&G land.

3.18. To the north of the village, modern arable farming techniques have removed some hedgerows and

created in places a more open character to the rolling countryside around Woodside, the

motorway corridor up to Junction 11 and the urban edge of the Luton/Dunstable conurbation.

Visual Amenity and Intervisibility of the Site and its Setting

3.19. There are limited long views of the surrounding landscape from the site. The top of the distant

Luton Hoo ridge can currently be glimpsed from the Church Road end of the site over an elevated

section of the motorway, where the natural ground falls away into the northern end of the Hoo

and Slip End valley along Newlands Road. The planting on the realigned northbound slip road

around the Church Road bridge is yet to fully establish but once this vegetation reaches maturity,

along with the extensive landscape buffer proposed beside this vegetation, these long views from

the site and Church Road will disappear.

3.20. There are some reverse views from the north back to Slip End and the tree-lined site boundary on

Church Road from Woodside and public rights of way in the countryside running over the large

open fields. There are also views back from the ridge at Stockwood Park and Newlands Road but

from these locations the site is mainly screened by the M1 and the tall vegetation running along

the motorway boundary, which would be greatly reinforced by the proposed widened landscape

buffer along the site boundary.



3.21. The enclosed nature of the landscape around eastern side of Slip End means there is little

intervisibility with wider landscape and the visual envelope around the landholding is limited. The

flat ridge top landform and combination of existing vegetation around the development area

prevent long views and leave the site visually and physically separated from the neighbouring

countryside.

3.22. Any visual effects from the proposed scheme would not have any significant adverse influences on

the character or appearance of the wider adjacent countryside around the village.

Landscape Character and Sensitivity

3.23. The local authority’s Landscape Character Assessment (LCA) no longer provides a character and

visual sensitivity rating for each character area. However, the companion Landscape Appraisal

demonstrates that the proximity of Slip End to the motorway and other adjacent urban influences

reduce the level of sensitivity of the landholding and its immediate setting when compared with

the overall character of the rural area.

3.24. The landscape attributes and their sensitivity are identified in the CBC LCA assessment of Area 12C

(Slip End Chalk Valley) and Area 11B (Caddington-Slip End Chalk Dip Slope). The boundary between

these two areas follows an arbitrary contour across the landholding with Area 12C covering the

majority of the field and its description is more representational of the site characteristics (see

Landscape Appraisal, Appendix A Fig.03).

3.25. The CBC assessment recognises the sensitivity of the L&G land to the prominent audible and visual

presence of the motorway and identifies the ridge crests along the M1 valley north of Slip End as

being particularly sensitive. However, the Slip End landholding is positioned on a part of the ridge

where there is no pronounced scarp crest or steep side to the valley but the land does fall gentle

across the site to the northern part of the motorway junction.

3.26. The visual sensitivity of the L&G land and the allotments is generally limited by the flatter landform

and visual containment provided by the tall blocks of vegetation around the site boundary.

Ability of the L&G Land and Allotments at Slip End to Accommodate Development

3.27. The existing contained nature of the proposed development site, its physical and visual separation

from the surrounding landscape, in combination with the proposed substantial boundary



landscape buffers and green infrastructure, would ameliorate the most significant adverse effects

of development.

3.28. Slip End village and the L&G land are located on a visually less prominent dip slope location

favoured by the local authority in preference to exposed crests on chalk scarps in the area. The

flatter location is also more compatible to construction than the steep sided valley slopes.

3.29. Although well maintained in productive arable use, the site is not a valued or distinguished

landscape and is otherwise ordinary and common place in terms of its land use in rural

Bedfordshire and the surrounding countryside.

3.30. The proximity to the settlement edge of Slip End and junction 10 of the motorway means the site

is subject to significant urban influences despite its rural fringe location.

3.31. The Landscape Appraisal demonstrates that the topographical features and containment around

L&G land and the allotments provide it with a good capacity to accommodate development,

notwithstanding its Green Belt designation.



4. DEVELOPMENT PROPOSALS

Figure 3: Conceptual Landscape Strategy

4.1. The scheme layout would be designed to create a high quality residential development that

respects the character of the area and the existing built form of the village as well as preserving

the local landscape character and visual amenity of the area. This would be achieved by enhancing

and renewing existing strategic, sensitive landscape features and protecting the visual amenity of

the area through a landscape led approach to the design and treatment of the land. A Conceptual

Landscape Strategy has been prepared for the site (Figure 3: Conceptual Landscape Strategy,

above) to demonstrate how the green infrastructure would maintain the enclosed character and

dictate the location and extent of the proposed built development.



4.2. The proposals for the 12 hectares of developable land would consist of predominantly 2-storey

dwellings set within a strong landscape framework wrapping around the site, with 8 hectares

including widened landscape buffers and recreational amenity space of approximately 100 metres

width along the entire motorway boundary. This zone would include all existing on-site vegetation

and new informal recreational facilities.

4.3. The existing allotment area would be used to ctreate a village green and include an equipped

children’s play area to form the hub to the development and focal point for the village. A

sustainable urban drainage system would also be incorporated into the buffers in a series of

landscaped swales and ponds to complement the appearance of the development and increase

biodiversity.

4.4. The landscape buffers would increase the screening of the motorway and include new noise

attenuation measures for the new development as well as benefiting the whole of the village.

4.5. The creation of substantial green corridors within the development along the main vehicular

access routes would also enhance the character of the location, as well as improve the rural

approaches to the village. New allotments would be created within the development boundary.

4.6. The proposals would enhance the existing public footpath that crosses the middle of the

landholding and bridleway that runs through the existing tree belt and proposed landscape buffer

along the eastern boundary. Both public rights of way would be set within their own green

corridors to create attractive routes that will encourage connectivity between the village, the new

development, and the adjacent countryside.



5. GREEN BELT APPRAISAL

Green Belt Designation and Policy

5.1. The L&G landholding lies towards the northern edge of London’s Metropolitan Green Belt, which

wraps around the Luton Borough boundary. Locally, the responsibility for the designation is more

complicated with the wider setting being covered by three local authorities. Slip End and the L&G

land are located entirely within Green Belt at a narrow neck of land that forms part the Central

Bedfordshire Council administrative area. The local authority’s land extends across the M1 at

Junction 10 between Slip End and Pepperstock, in the west, and Luton Hoo to the east (see Figure

4, below).

Figure 4: Green Belt

5.2. To the south, the Green Belt boundary between the CBC district and the northern edge of the

Dacorum Borough Council administrative area follows an arbitrary line along field boundaries

south of Pepperstock. The countryside within the adjacent parts of Dacorum are also designated



Green Belt. To the east, the Luton Borough Council administrative area runs along the opposite

side of the motorway and arrives at its most southerly point at Junction 10 and the M1 spur road

to Luton Airport (New Airport Way). None of the adjacent land in Luton, which includes Stockwood

Park, forms any part of the Green Belt designation.

5.3. Local Green Belt policies reinforce the NPPF. Policies associated with the site and the surrounding

countryside are:

• Central Bedfordshire Council: Policy GB1 - Green Belt

• Dacorum Borough Council: Policy 4 – Green Belt

Compliance with the Purposes of Green Belt

Introduction

5.4. The NPPF (para. 79) states that the Government attaches great importance to Green Belts with

their fundamental aim being to prevent urban sprawl by keeping land permanently open; the

essential characteristics being their openness and their permanence.

5.5. The five purposes of the Green Belt are defined in para. 80 as being:

• To check unrestricted sprawl of large built up areas;

• To prevent neighbouring towns from merging into one another;

• To assist in safeguarding the countryside from encroachment;

• To preserve the setting and special character of historic towns; and

• To assist in the urban regeneration by encouraging the recycling of derelict and other urban

land

5.6. Planning decisions and Green Belt assessments prior to the 2016 Court of Appeal ‘Turner’ ruling

were primarily based on a ‘volumetric’ or ‘spatial’ exercise that considered ‘openness’ as

essentially freedom from development – either built form or engineering works. Where exceptions

may be considered ‘not inappropriate’ in Green Belt (NPPF paras. 89 and 90) they are generally

still required to preserve ‘openness’ and comply with the purposes of the Green Belt designation.

5.7. The 2016 ‘Turner’ judicial review has confirmed a ‘visual dimensions’ to the interpretation of the

NPPF.

Paragraph 14 of the ruling states:



“The concept of ‘openness of the Green Belt’ is not narrowly limited to the volumetric approach…..

The word ‘openness’ is open-textured and a number of factors are capable of being relevant when

it comes to applying it to the particular facts of a specific case. Prominent among these will be

factors relevant to how built up the Green Belt is now and how built it up it would be if development

occurs………….and factors relevant to the visual impact on the aspect of openness which the Green

Belt presents.”

Paragraph 15 then goes on to state:

“The question of visual impact is implicitly part of the concept of ‘openness’ of the Green Belt as a

matter of the natural meaning of the language used in para. 89 of the NPPF. I [Lord Justice Scales]

consider that this interpretation is also reinforced by the general guidance in paras. 79-81 of the

NPPF… . There is an important visual dimension to checking ‘the unrestricted sprawl of large built-

up areas’ and the merging of neighbouring towns, as indeed the name ‘Green Belt’ itself implies.

Greenness is a visual quality: part of the idea of the Green Belt is that the eye and spirit should be

relieved from the prospect of unrelenting urban sprawl. Openness of aspect is a characteristic

quality of the countryside, and ‘safeguarding the countryside from encroachment’ includes

preservation of that quality of openness. The preservation of ‘the setting … of historic towns’

obviously refers in a material way to their visual setting, for instance when seen from a distance

across open fields. Again, the reference to para. 81 to planning positively ‘to retain and enhance

landscapes’ visual amenity and biodiversity’ in the Green Belt makes it clear that the visual

dimension of the Green Belt is an important part of the point of designating land as Green Belt.”

CBC Central Bedfordshire Development Strategy: Green Belt Technical Paper (2014)

5.8. The purpose of the first study paper prepared by CBC was:

“to set out the ‘exceptional circumstances’ which the Council believes justifies the release of Green

Belt land, and to summarise the methodology employed in reviewing the existing boundaries of the

Green Belt. In doing so it is hoped that it will provide a sound basis for the release of Green Belt

land and the identification of urban extensions as proposed by the development strategy.”

5.9. Green Belt policy in South Bedfordshire originated in the 1960’s when there was considerable

growth pressures on the main towns in the area (Luton, Dunstable, Houghton Regis, Ampthill and

Flitwick) (ref: Technical Paper Section 2), which coincided with the completion of the M1

motorway. The Paper identified a requirement for substantial new growth to meet housing needs



and to achieve the required numbers in the plan period up to 2031. The Paper accepts that

development was required on Green Belt land (Paper Section 4) and Southern Central

Bedfordshire was identified as having the greatest housing need (4.3.1 and 9.1).

5.10. Having identified the exceptional circumstances to justify the release of Green Land the Technical

Paper undertook a systematic identification of sites. The study sought to identify larger tracts of

land that had least impact on Green Belt principles and were located close to areas of most need

(Section7).

5.11. The authority’s assessment was undertaken in two stages. Part 1 (Section 8) was a high-level

strategic assessment that divided the administrative area into parcels based on Parishes with each

parcel determined on its performance against the five purposes of the Green Belt. Part 2 (Section

9) reviewed boundaries in relation to specific smaller areas and locations where there was a

proven intent to develop (9.3).

5.12. The Slip End site was not assessed individually at either stage but its inclusion in larger land parcels

that were judged to be more sensitive Green Belt land. This meant the village was considered to

be part of an area to the ‘West of Luton’ (and the M1) that contributed most in the purposes of

Green Belt and was not regarded as appropriate for development.

Central Bedfordshire and Luton Green Belt Study (2017)

5.13. The methodology used for the 2017 CBC assessment is set out in chapter 3 of the document. Unlike

the previous 2014 study, only the contributions made to the first four purposed of the Green Belt

(as listed in 5.5 above) were reviewed. Purpose 5 was excluded because all parts of the Green Belt

in the administrative area have the potential to make a strategic contribution to urban renewal

but it was not considered possible to quantify how any individual land parcel delivers against this

purpose.

5.14. It is common practice for Green Belt studies to exclude both Purpose 4 and 5 from assessments,

particularly with Purpose 4 where a town or city is not recognised as being a historic settlement of

special character as defined in the NPPF. The CBC assessment describes the historic development

of Luton and its setting (3.53 to 3.56) rather than providing the evidence base to support the

proposition that the limited cultural and heritage attributes are of sufficiently special character or

quantity to warrant the town being given historic status for Green Belt purposes.



5.15. In setting the context for the town, the adopted Luton Local Plan 2001-2011 provides a more

mundane description of its ‘main features’:

“3.11 Luton is a busy town, with a centre focused upon a large Arndale shopping centre. To the

north of the central area, extending from Plaiters Lea to High Town, is the area previously

dominated by the hat industry. The surrounding areas were intensively developed during the

industrial revolution, and still contain a mix of residential and employment uses. Some substantial

parks were created during the Victorian period and they still exist today. During the first half of the

20th century, major employers, such as Vauxhall, Electrolux and SKF, developed their businesses in

the town.”

“3.12 Housing development has taken place at a steady rate since the end of the First World War,

with 40% of the total stock being built between 1970 and the end of the 20th century. Luton is now

generally developed up to its administrative boundary.”

5.16. The first stage of the CBC study divides the Green Belt into a series of land parcels around the

‘inset’ villages and towns, and subdivides the remaining areas of Green Belt into ‘broad areas’ -

Area SE1 for Slip End falls within the former category. Each parcel was assessed for each of the

four purposes of the Green Belt on the 5-point scale according to the relative strength or weakness

of the contribution.

5.17. Stage 2 drew on the Stage 1 work to ‘isolate’ areas of Green Belt judged to make no more than a

‘relatively weak’ contribution to all of the Green Belt purposes - a total of 29 areas were identified.

Land achieving a higher rating (‘moderate’, ‘relatively strong’ or ‘strong’ contributions) were not

included because it was considered that making a higher contribution to just one purpose of the

Green Belt posed a greater risk of harm. However, the desk-based judgements needed on such a

wide-ranging study meant the authors decided to include parcels with ‘borderline’ ratings

between the ‘moderate’ and ‘weak’ contribution categories.

Analysis of the CBC 2017 Green Belt findings for Area SE1

5.18. The area around the Slip End settlement boundary was divided into two with Area SE1 (including

the L& G land) to the south-east of the B4540, and Area SE2 to the north-west of the B4540. Both

had identical results and were taken forward to stage 2. This Review will only deal with reduced

Area SE1a taken through to stage 2, which still included the area to the south-east of Slip End, and

the L&G land, but excluded Pepperstock.



Stage 1 Assessment of Purposes of the Green Belt

Test 1: To check unrestricted sprawl of large built up areas

Commentary:

CBC Green Belt Study findings for Purpose 1: considered to make a ‘Moderate’ contribution

5.19. The scheme proposals would extend built form onto a previously undeveloped strip of agricultural

Green Belt land between the Slip End settlement boundary and the M1 motorway at Junction 10.

However, Slip End is defined as a village not a large built-up area in policy terms and the provision

of an appropriately well designed urban extension in keeping with the village character, and to

fixed boundaries does, not constitute unrestricted sprawl.

5.20. The landholding is located in a transitional zone where the increasing urban artefacts and similar

development on, or close to, a major motorway junction on a nationally important transport

corridor already heavily influence the character of the land and visual appreciation of its setting.

5.21. The companion ‘Landscape Appraisal’ demonstrates that there is extremely limited intervisibility

between the site and its setting because of the surrounding ground form and vegetation in and

around the site boundary. The retained site vegetation and extensive landscape mitigation

treatments included in the development proposals would reinforce the well-vegetated character

of the site and reduce the visual effects of massing and scale on the village and its immediate

setting.

5.22. While it is accepted that development on the joint site would irreversibly alter the character of the

land, the same case could be made for any built development on countryside in Green Belt land.

5.23. The difference with the L&G land is the ‘visual dimension’ - the lack of intervisibility and the more

remote and visually self-contained attributes of the site, both from the exiting village and the

surrounding Green Belt land.

5.24. The proposed development would complement the existing built form, provide new access and

retain substantial green areas for recreation and both physical and visual amenity. The substantial

landscape buffers along the motorway boundary would also provide an enduring and well-defined

edge to the settlement.



5.25. The site is undistinguished in landscape and environment terms and the use of this land should be

preferred to development of other Green Belt land in more sensitive, prominent or remote

countryside locations.

5.26. The L&G land, within the wider SE1a area, is considered in visual terms to make a ‘relatively weak’

contribution (low risk of harm from release) to Purpose 1 and development could be achieved

without any significant effects on the visual integrity of the surrounding Green Belt or character of

the area.

5.27. The CBC assessment of the site making a ‘moderate’ contribution (moderate risk of harm from

release) to Purpose 1 is not agreed. It is considered that the visual characteristics and nature of

the development on the L&G land mean it makes a weaker contribution to the sense of sprawl and

would cause less risk from harm for the Green Belt.

Test 2: To prevent neighbouring towns from merging into one another

Commentary:

CBC Green Belt Study findings for Purpose 2: considered to make a ‘Weak/No’ contribution

5.28. The nearest major town of significant size is the southern settlement edge to Luton on the opposite

side of the motorway. Dunstable lies 4.0 km to the north-west, Harpenden 3.0km to the south east

and Hemel Hempstead 6.0km to the south in straight-line distances between the site and closest

point on each settlement boundary. The distances to each town are too great and development is

not of sufficient extent to create a physical or visual sense of merging with these towns, which are

also surrounded by Green Belt.

5.29. There is limited intervisibility with the landscape to the north around Woodside. The L&G land lies

to the south of Church Road and would not create a sense of coalescence between Slip End and

Woodside. Caddington lies further north and is not visible from the proposed development area

because of the intervening vegetation and generally flat landform. From the Pepperstock area and

countryside to the west of Slip End, the L&G land would also be hidden by intervening vegetation

and the proposed landscape buffer that would be retained in the southern section of the

landholding along Front Street.



5.30. The boundary with Luton is separated physically by the substantial width of the M1 corridor

although the landscape around Newlands Road and the Stockwood Park golf course has an urban

fringe character with a collection of urban artefacts associated with the motorway junctions and

prominent overhead power lines present in views. Development of the site is unlikely to alter the

visual relationship between Slip End and the hidden urban edge of Luton. Intervisibility would be

further reduced with the proposed reinforcement of the landscape buffer along the motorway

boundary beside Church Road.

5.31. The CBC assessment of the site making a ‘weak/no’ contribution (very low/no risk of harm from

release) to Purpose 2 is agreed.

Test 3: To assist in safeguarding the countryside from encroachment

Commentary:

CBC Green Belt Study findings for Purpose 3: considered to make a ‘Moderate’ contribution

5.32. The site forms part of a buffer strip of agricultural land between the motorway and the village

edge, which currently varies in width between 170 metres, at its closet point, and 290 metres along

the Church Road frontage. This enclosed and narrow piece of land is already visually separated

from the surrounding Green Belt countryside by the topography, the motorway, substantial blocks

of surrounding vegetation and the existing built form of Slip End.

5.33. Significant future boundary buffer planting would create a further physical and visual sense of

separation between the L&G land and the countryside to the north, south and west of the village

whilst still preserving the adjacent countryside character and complementing the character and

appearance of Slip End.

5.34. The site has a contained zone of visual influence and makes a limited contribution to the

appreciation of the wider countryside around Slip End. The site is generally seen in the context of

the motorway when viewed from the roads leading to or from the village. The site plays a limited

part in safeguarding the main part of the open countryside around the village from encroachment

and its use for housing would not prevent the village from retaining its rural character and

important physical relationship with the existing surrounding Green Belt countryside to the north,

south and west.



5.35. Development of the enclosed L&G landholding and the allotment area would avoid the need to

use more visually prominent or sensitive alternative Green Belt land in the surrounding rural

landscape to meet housing supply quotas in the southern part of Central Bedfordshire.

5.36. The CBC assessment of the site making a ‘moderate’ contribution (moderate risk of harm from

release) to Purpose 3 is not agreed. The L&G land is considered to make a ‘relatively weak’

contribution (low risk of harm from release) to Purpose 3. The visually enclosed nature of the site

means development would avoid any significant sense of encroachment. Development could be

achieved without any significant effects on the visual integrity or character of the surrounding

countryside in the Green Belt.

Test 4: To preserve the setting and special character of historic towns

Commentary:

CBC Green Belt Study findings for Purpose 4: considered to make a ‘Weak/No’ contribution

5.37. Slip End is not a designated historic settlement, nor is Luton a historic town whose character or

setting has been designated as special in policy terms for either its appearance or heritage value.

5.38. The urban area of Luton is not visible from the L&G landholding in Slip End and the only view into

suburban edge of Luton is of Stockwood Park, a major sports and recreational area. The only part

of this large park visible from Slip End is the west facing ridge slope that is used as a golf course.

This landscape has no historical significance other than its Victorian origins, and is not visually

recognisable as forming part of Luton.

5.39. The L&G land and adjacent part of Stockwood Park are both heavily influenced by the adjacent M1

motorway, which dominates the setting to both Slip End and extreme south-west tip of Luton.

5.40. The CBC assessment of the site making a ‘weak/no’ contribution (very low/no risk of harm from

release) to Purpose 4 is agreed.

Stage 2 Assessment of Purposes of the Green Belt

5.41. The detailed Study divides the Area SE1a land, to the south-east of the B4540, into three. The L&G

landholding north of Front Street forms the eastern section. The western section stretches

between the Slip End Lower School on the Markyate Road and the Brickhill Park residential



development on Half Moon Lane in Pepperstock. The central section of the area runs from the

village edge at Crawley Close, along the southern side of Front Street opposite the village

allotments and the L&G land to Half Moon Lane in Pepperstock.

5.42. The Stage 2 study provides only a brief assessment of the three sub-parcels with a cursory overview

of the landscape characteristics and visual relationship between the area and its setting. The

assessment for the L&G land states:

“The motorway forms strong containment to the north and east, but a mature well-treed hedgerow

provides a strong visual barrier and there is no built development within the parcel north of Front

Street. The landform in this area adds to the sense of distinction from the inset settlement: a

distinct valley cuts through the centre of the northernmost field, parallel to Church Road, and to

the east the land slopes down towards the motorway.”

“Land to the south-east between Slip End and Pepperstock is more contained by development and

also occupies high ground at a similar elevation, and so relates less strongly to the wider

countryside, but to the west of this the landform falls away, and the parcel’ outer boundary is

weaker, giving the area a stronger relationship with the countryside to the west.”

“The parcel is too separate from Luton to contribute to its historic setting.”

5.43. Given this analysis of the three sub-parcels that make up Area SE1a, there does not seem to be

any logical progression in either ‘volumetric’ or ‘visual’ terms to the conclusions reached:

Central parcel:

“The fields contained by Front Street, by the inset settlement edge of Slip End on Crawley Close, by

Half Moon Lane [in Pepperstock] and by a hedgerow to the south-west, as indicated on the map

above, are considered to make a relatively week contribution to the Green Belt purposes. These

features would form a stronger potential alternative Green Belt boundary than the inset edge, but

would call into question the status of the adjacent Park Home development at Pepperstock.”

East & West Parcels:

The parcels to the west and east (the latter being the L&G land north of Front Street) received no

further explanation of their landscape or visual significance to the Green Belt and were simply

grouped together and judged to make:

“…a moderate contribution to preventing encroachment on the countryside.



5.44. While the ‘weak’ contribution made by the Central parcel of SE1a is accepted, there is no clear

reason for this sub-area scoring less in Green Belt terms than the other sub-parcels to the east and

west. New development on either of the western or central parcels, which are larger-scale and

semi-open landscapes, would create coalescence between the Markyate Road and Crawley Close

in Slip End and Half Moon Lane in Pepperstock. The western parcel, as recognised in the parcel

description, also has a stronger relationship to the Green Belt countryside to the west and if

developed would create an obvious sense of encroachment into the rural landscape.

5.45. The conclusions fail to give any significant weight to the different physical and visual characteristics

of the L&G land north of Front Street and their benefits over the other two sub-parcels to the south

of Front Street in visual Green Belt terms. The high level of containment provided around the entire

perimeter of the L&G site by the boundary vegetation visually separates the landholding from the

adjacent surrounding countryside. This is already physically reinforced by the intervening built

form of Slip End to the west and the extensive M1 junction to the east. The shorter boundaries

along Front Street to the south and Church Road are also lined by vegetation. This sense of visual

enclosure does not occur to the same degree on the other two more open sub-parcels.

5.46. Unlike the CBC Study, this Review considers that the L&G land is visually different to the other two

sub-parcels in Area SE1a, it makes the weakest contribution to the purposes of the Green Belt and

would create the least risk of harm if released from the designation. The development proposals

would retain a substantial proportion of the land as new multi-functional green infrastructure and

provide accessible public open space.

Overall Assessment

5.47. The L&G site is a discrete and self-contained piece of land that has the capacity to accommodate

development without any appreciable effects on the character of the adjacent countryside or the

integrity of the surrounding Green Belt – unlike the other parcels in Area SE1a.



6. SUMMARY AND CONCLUSIONS

6.1. The proposed development site at Slip End lies within designated Green Belt. The introduction of

any development onto the L&G and Luton Hoo estate land at Slip End would be contrary to the

strict volumetric concept of ‘openness’ implicit in NPPF Green Belt policy. However, the ‘Turner’

judicial ruling in 2016 has confirmed the need to introduce a visual dimension in addition to the

volumetric exercise traditionally undertaken in decision-making and assessing the purposes of the

Green Belt designation.

6.2. The visual assessment included in this Review has taken into consideration the perception of

openness, the intervisibility between the site and its setting as well as the limited zone of visual

influence between the L&G site and its Green Belt setting.

6.3. This Review disagrees with the conclusions reached by the two stage assessment included in the

‘Central Bedfordshire and Luton Green Belt Study’ published in July 2017 in relation to the L&G

land. The study adopts the strict traditional ‘volumetric’ approach to the methodology and does

not take into account the ‘visual dimension’ to Green Belt assessment as directed by the Turner

ruling. Consequently, the local authority’s study does not give due regard to the visual implications

for the purposes of the Green Belt as set out in the NPPF and fails to acknowledge or give weight

to the distinct visual benefits of the L&G landholding.

6.4. The visual consideration generally has the effect of weakening the L&G site’s contribution to the

purposes of the Green Belt as suggested in the CBC 2017 Study and lowering the potential risk of

harm of releasing the land from the designation.

6.5. The proposed L&G development site has a high level of visual and physical containment created

by a complementary combination of vegetation, land form and existing built development in the

form of Slip End village and the substantial M1 motorway junction that forms a barrier between

Slip End and the settlement boundary of Luton .

6.6. The L&G land is not subject to any other significant landscape or environmental planning policies

other than Green Belt designation. The heritage and cultural attributes of the land are also

insufficient to warrant its classification as a ‘valued’ landscape. The arable field is undistinguished

and has no rarity value in terms of its appearance or land use in the Bedfordshire countryside.



6.7. The combination of landscape and visual attributes give the land off Front Street and Church Road

a good capacity to accommodate residential development. The proposed development would

respond sympathetically to the setting, include a wide range of recreational and amenity facilities

set within a strong green framework that would enhance the village and increase on-site

biodiversity. The proposed village green would form a focal point for Slip End.

6.8. The landscape strategy and associated boundary buffers would establish a clearly defined,

enduring and appropriate new landscaped settlement edge to Slip End against the motorway

boundary. The landscape treatments would also ensure the development would not cause

significant harm to the character of the immediate setting or visual integrity of the remaining

Green Belt designation in the area.

6.9. The authority’s preface to the 2017 Green Belt Study acknowledges that less than 1% of Central

Bedfordshire’s Green Belt was assessed as performing weakly, and may not necessarily be suitable

for development for a variety of reasons. The Study concluded that it would be necessary to

release better performing areas of Green Belt land in order to realise the strategy set out in the

Local Plan, although no indication was given to a new threshold being set to include more strongly

performing land parcels.

6.10. The conclusion reached in this Review, when taking into consideration the visual implications, is

that the L&G landholding should qualify in its own right for consideration as a weaker category site

that would be of low risk of harm for release from the Green Belt. However, if taken as a

‘moderate’ ‘borderline’ land parcel, as suggested in the local authority’s study, then the site, in

any event, should be next for consideration in any logical sequential landscape-led approach to

site selection.

6.11. If Green Belt land is to be used for development it is preferable, in landscape and visual terms, to

use environmentally undistinguished sites next to existing settlements, such as the L&G

landholding, rather than that take more sensitive, valued, visually prominent or remote locations

within the designation.

6.12. The L&G land at Slip End is, therefore, suitable for consideration for release from the Green Belt

for a residential allocation in the emerging Central Bedfordshire Local Plan.

land off front street at slip end, luton

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